United States v. Lance Longie

Court of Appeals for the Eighth Circuit·Decided July 28, 2026·No. 24-3302·Published

Opinion

United States Court of Appeals For the Eighth Circuit ___________________________

No. 24-3302 ___________________________

United States of America

lllllllllllllllllllllPlaintiff - Appellee

v.

Lance Quintin Longie

lllllllllllllllllllllDefendant - Appellant ____________

Appeal from United States District Court for the District of South Dakota - Northern ____________

Submitted: October 24, 2025 Filed: July 28, 2026 ____________

Before LOKEN, BENTON, and SHEPHERD, Circuit Judges. ____________

LOKEN, Circuit Judge.

In February 2004, Lance Quintin Longie pleaded guilty in a Moorhead, Minnesota state court to criminal sexual conduct in the first degree. He was classified as a Tier III sex offender under Minnesota law, requiring him to register as a sex offender under state law and maintain his federal registration status under the Sex Offender Registration and Notification Act (“SORNA”). Longie was released from custody, commenced supervised release, and registered in Minnesota in 2011. In 2020, he was found guilty after trial of a second Predatory Offender violation in Moorhead state court for knowingly violating registration requirements and intentionally providing false information. He was sentenced to 24 months.

Longie was released by the Minnesota Correctional Facility in St. Cloud on May 31, 2022 after stating on a Predatory Offender Registration Change of Information Form that he would reside at the Dorothy Day House in Moorhead. On June 1, Longie and his mother met with supervised release agent Matthew Rapp to discuss conditions and registration requirements. Homeless at the time (Dorothy Day House did not have space for him), Longie expressed an interest in moving to North Dakota or South Dakota for employment. Agent Rapp explained that Longie must provide specific information and Rapp would then submit an interstate travel application for approval. Longie and Rapp met again on June 15 to discuss registration requirements. He appeared at the Moorhead Police Department and registered as living in Moorhead on June 29. A third meeting was rescheduled to July 14; Longie failed to show and had no further contact with Agent Rapp. Instead, he spent time with his father in North Dakota around the July 4th holiday and later moved to South Dakota to live with his mother. He did not register in North or South Dakota and a warrant issued for his failure to comply with SORNA requirements.

In March 2024, when Longie had not registered with law enforcement for approximately 632 days, the Sheriff’s Office in Roberts County, South Dakota received a tip he was residing with his mother in New Effington. Executing the warrant, officers found Longie hiding in the bathroom. He was charged with one count of failure to register as a sex offender in violation of 18 U.S.C. § 2250(a). He entered a not guilty plea, exercised his right to a jury trial, and on the eve of trial submitted jury instruction requests that included an instruction on the “uncontrollable circumstances” affirmative defense in 18 U.S.C. § 2250(c):

-2- (c) Affirmative Defense. -- In a prosecution for a violation under subsection (a) or (b), it is an affirmative defense that --

(1) uncontrollable circumstances prevented the individual from complying;

(2) the individual did not contribute to the creation of such circumstances in reckless disregard of the requirement to comply; and

(3) the individual complied as soon as such circumstances ceased to exist.

During the one-day trial, the jury heard testimony offered by the defense to establish an uncontrollable circumstances affirmative defense. The district court1 excluded testimony from Longie and his mother about “conditions” Longie faced in Minnesota that followed him to North and South Dakota, and threats and threatening behavior by unnamed individuals that allegedly prevented him from fulfilling his registration requirements. At the close of evidence, the district court declined to instruct the jury on the § 2250(c) affirmative defense, rejecting defense counsel’s argument that the “treatment, harassment, threats” kept Longie from registering:

[T]hat’s not sufficient. I’m not going to instruct on so-called uncontrollable circumstances. There is absolutely no evidence of that. No credible evidence on that. No evidence of anything reported to law enforcement.

The jury convicted Longie and he was sentenced to 45 months in prison. He now appeals, arguing the district court erred in (1) excluding this testimony and (2) refusing to instruct the jury on his affirmative defense. We affirm.

1 The Honorable Charles B. Kornmann, United States District Judge for the District of South Dakota.

-3- Discussion

A. Interpreting the Affirmative Defense. SORNA’s legislative history reported that its purpose when enacted in 2006 was to “make more uniform what had remained a patchwork of federal and 50 individual state registration systems, with loopholes and deficiencies that had resulted in an estimated 100,000 sex offenders becoming missing or lost,” Nichols v. United States, 578 U.S. 104, 111-12 (2016) (quotation omitted), which was especially troubling because sex offenders have a higher rate of recidivism than other offenders, United States v. Gould, 568 F.3d 459, 472 (4th Cir. 2009) (citation omitted). Congress therefore criminalized knowing failure to register or update a sex offender registration in 18 U.S.C. § 2250(a), subject to the uncontrollable circumstances affirmative defense in § 2250(c). Case law applying § 2250(c) and its three statutory elements is sparse; we have not addressed the defense, nor have many of our sister circuits.

The task of interpreting the meaning of a statute “begins where all such inquiries must begin: with the language of the statute itself. . . . [W]here . . . the statute’s language is plain, the sole function of the courts is to enforce it according to its terms. . . . The plain meaning of legislation should be conclusive, except in the rare cases in which the literal application of a statute will produce a result demonstrably at odds with the intentions of its drafters.” United States v. Ron Pair Enters., Inc. 489 U.S. 235, 242 (1989) (cleaned up). Here, the elements of the defense are spelled out in great detail in § 2250(c) but are not addressed in SORNA’s extensive legislative history. The few reported cases addressing § 2250(c) do not “begin[] . . . with the language of the statute itself,” so they are not reliable interpretive precedent.

Fortunately, Congress itself provided that guidance by using almost the exact same language in a statute enacted a few years before SORNA. See 18 U.S.C.

-4- § 3146(c), a provision of Title II of the comprehensive Sentencing Reform Act of 1984, known as the Bail Reform Act amendments.

§ 3146. Penalty for failure to appear

* * * * *

(c) Affirmative defense. It is an affirmative defense to a prosecution under this section that uncontrollable circumstances prevented the person from appearing or surrendering, and that the person did not contribute to the creation of such circumstances in reckless disregard of the requirement to appear or surrender, and that the person appeared or surrendered as soon as such circumstances ceased to exist.

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United States v. Lance Longie, (8th Cir. 2026).

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